Texas A&M University-Victoria Student Financial Aid Code of Conduct
Texas A&M University-Victoria participates in education loan programs under Title IV of the Higher Education Act of 1965, as amended. All employees with responsibilities related to education loans must follow this policy and the Student Financial Aid Code of Conduct.
Texas A&M University-Victoria will annually notify relevant employees of the code of conduct, and the policy will be prominently posted on the university website. Employees must comply with applicable Board of Regents policies, System Administrative Memoranda, and Texas and federal law. If a conflict exists between this code and any policy or law, the policy or law prevails.
Conflicts of Interest
Employees must avoid conflicts of interest related to education loans, including Federal Family Education Loans and private education loans.
Gifts
Employees in financial aid roles may not solicit or accept gifts from lenders, guarantors, or servicers. This includes gifts given to family members or others if linked to the employee’s official position. A “gift” is any item of value exceeding a minimal amount, including services, transportation, lodging, meals, or entertainment.
Permitted items include:
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Standard materials or programs related to loans, default prevention, or financial literacy.
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Food, training, or materials provided as part of professional development.
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Favorable loan terms for students, if offered to all students equally.
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Entrance and exit counseling, provided the university controls the content and no lender-specific promotion occurs.
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Philanthropic contributions unrelated to loans.
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State-administered education grants or financial aid funds.
Advisory Board Compensation
Employees serving on lender-established advisory boards may not receive anything of value, except reimbursement for reasonable expenses.
Contracting Arrangements
Employees may not accept payments or benefits from lenders for consulting or other contracts related to Federal Family Education Loans or private education loans. Exceptions:
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Employees not in financial aid may serve on boards with proper recusal from loan-related decisions.
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Lender officers or contractors may serve on the Board of Regents with proper recusal.
Stock Ownership
Employees in financial aid roles may not hold ownership in lenders, except through publicly traded mutual funds or similar investments where they do not control investment decisions.
Interaction with Borrowers
Texas A&M University–Victoria may not:
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Assign a borrower’s loan to a specific lender.
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Delay or deny certification of a loan based on the borrower’s lender choice.
Private Loan Funding Offers
Texas A&M University–Victoria may not request or accept funds from lenders in exchange for preferential treatment or volume commitments.
Staffing Assistance
Texas A&M University–Victoria may not accept lender-provided staffing for the financial aid office, except for:
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Professional development training for staff.
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Educational or financial literacy materials, with disclosure of lender involvement.
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Short-term emergency staffing assistance during natural or localized disasters.
Revenue-Sharing
Texas A&M University–Victoria may not enter into revenue-sharing arrangements with lenders. A revenue-sharing arrangement involves the institution recommending a lender in exchange for financial benefit.
Definitions
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Federal Family Education Loan: A loan made, insured, or guaranteed under Part B, Title IV, of the Higher Education Act.
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Lender: An eligible Federal Family Education Loan lender, a private educational lender, or anyone engaged in providing education loans.
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Private Education Loan: A non-Title IV loan made by a private lender for postsecondary education expenses.
Additional Prohibitions
Employees may not:
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Award or disburse the same transaction twice.
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Participate in awarding or administering aid where a real or apparent conflict of interest exists, including involving family members or partners.
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Manipulate award dates to favor themselves or related parties.